OFAC - Venezuela General License 12 - Authorizing Certain Activities Necessary to Wind Down Operations or Existing Contracts with Petróleos de Venezuela, S.A. (PdVSA)

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Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

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TURBOFAC Commentary (606 words)

Notes:

*This is one of a handful of GLs that were active as of the date of the blocking of the Government of Venezuela (GOV) that were not amended to account for that fact. This is because it was expired when the GOV was blocked.

1) Venezuela 12 expired in April, 2019, with no further GLs issued to cover the activity within its scope.

2) Consult the Research System for GLs involving the scope of "wind down" general licenses, and compare Venezuela GL 11, which permits "maintenance" of operations; a concept broader than "wind down."

3) With respect to subsection (b), see Venezuela GL 7 - Authorizing Certain Activities Involving PDV Holding, Inc. and CITGO Holding, Inc.

4) Read in conjunction with Venezuela GLs 7-13, all of...

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Venezuela General License 12 - Authorizing Certain Activities Necessary to Wind Down Operations or Existing Contracts with Petróleos de Venezuela, S.A. (PdVSA) (Expired)

TURBOFAC Commentary (606 words)